In Re The Personal Restraint Petition Of Jacob Matthew Mejia

CourtCourt of Appeals of Washington
DecidedJuly 12, 2022
Docket55939-1
StatusUnpublished

This text of In Re The Personal Restraint Petition Of Jacob Matthew Mejia (In Re The Personal Restraint Petition Of Jacob Matthew Mejia) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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In Re The Personal Restraint Petition Of Jacob Matthew Mejia, (Wash. Ct. App. 2022).

Opinion

Filed Washington State Court of Appeals Division Two

July 12, 2022

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II

In the Matter of the Personal Restraint of: No. 55939-1-II

JACOB MATTHEW MEJIA,

Petitioner. UNPUBLISHED |OPINION

PRICE, J. — Jacob M. Mejia brings this personal restraint petition (PRP) arguing that he is

entitled to resentencing under State v. Houston-Sconiers1 because his crimes were committed when

he was 17 years old and the trial court did not consider his youth at sentencing. We agree, grant

Mejia’s PRP, and order resentencing.

FACTS

When Mejia was 17 years old, his six-week old son sustained serious injuries while under his

supervision. State v. Mejia, No. 42176-3-II, slip op. at 1 (Wash. Ct. App. Jul. 23, 2013),

https://www.courts.wa.gov/opinions/pdf/D2%2042176-3-II%20%20Unpublished%20Opinion.pdf.2

The State charged Mejia with first degree assault and second degree criminal mistreatment. Each

charge included a domestic violence special allegation and an aggravating circumstance allegation

for a particularly vulnerable victim. The jury found Mejia guilty on both charges and returned special

1 188 Wn.2d 1, 391 P.3d 409 (2017). 2 Unless otherwise noted, the facts in this opinion are from our decision in State v. Mejia. No. 55939-1-II

verdicts, finding the domestic violence and particularly vulnerable victim allegations were proven.

Id. at 6.

The standard sentencing range for Mejia’s first degree assault conviction was 120 to 160

months. The State requested an exceptional sentence upward. Defense counsel requested a sentence

at the low end of the standard range and specifically stated that because “age by itself is not a specific

mitigating factor,” it had decided not to request an exceptional sentence downward. PRP at 52. No

additional mention of Mejia’s age by the parties or the trial court was made during sentencing.

The trial court sentenced Mejia to an exceptional upward sentence of 300 months for his first

degree assault conviction, along with 17 months for his second degree criminal mistreatment

conviction to be served concurrently with his sentence on the first degree assault conviction. In its

decision, the trial court referenced Mejia’s lack of remorse and lack of appreciation of the

consequences of his actions. Mejia, slip op. at 13.

Mejia appealed his convictions and his sentence for the first degree assault conviction, and

we affirmed. We issued a mandate in December 2013.

In 2021, Mejia filed this PRP arguing that he is entitled to resentencing under Houston-

Sconiers.

ANALYSIS

A. LEGAL PRINCIPLES

Generally, petitioners have only one year from the date their judgment and sentence becomes

final to bring a PRP. RCW 10.73.090. Petitions filed after the one-year mark are time barred unless

an exception applies. RCW 10.73.100.

2 No. 55939-1-II

A petitioner can overcome the one-year time bar if they can identify (1) a significant change

in the law (2) that is material to their conviction or sentence and (3) that applies retroactively. RCW

10.73.100(6); State v. Miller, 185 Wn.2d 111, 114, 371 P.3d 528 (2016). Additionally, to obtain

relief in a PRP, the petitioner must also show actual and substantial prejudice resulting from the

alleged constitutional errors by a preponderance of the evidence. In re Pers. Restraint of Cook, 114

Wn.2d 802, 813-14, 792 P.2d 506 (1990). A petitioner “ ‘must shoulder the burden of showing, not

merely that errors at [their] trial created a possibility of prejudice,’ but that the outcome would more

likely than not have been different had the alleged error not occurred.” In re Pers. Restraint of

Meippen, 193 Wn.2d 310, 315-16, 440 P.3d 978 (2019) (internal quotation marks omitted) (quoting

In re Pers. Restraint of Hagler, 97 Wn.2d 818, 825, 650 P.2d 1103 (1982)).

In Houston-Sconiers, our Supreme Court held that when sentencing juveniles, the Eighth

Amendment requires courts to consider the “ ‘hallmark features’ ” of youth and have discretion to

impose a sentence below the standard range. 188 Wn.2d 1, 23, 391 P.3d 409 (2017) (quoting Miller

v. Alabama, 567 U.S. 460, 477, 132 S. Ct. 2455, 183 L. Ed. 407 (2012)); U.S. CONST. amend. VIII.

The hallmark features of youth include a juvenile’s “ ‘immaturity, impetuosity, and failure

to appreciate risks and consequences,’ ” along with “the nature of the juvenile’s surrounding

environment and family circumstances, the extent of the juvenile’s participation in the crime, and

‘the way familial and peer pressures may have affected [them].’ ” Id. (quoting Miller, 567 U.S. at

477). Trial courts must also examine factors that indicate a likelihood of rehabilitation and the

impact of youth on the juvenile’s legal defense. Id.

Following Houston-Sconiers, our Supreme Court held that “a petitioner [seeking relief under

Houston-Sconiers] establishes actual and substantial prejudice when a sentencing court fails to

3 No. 55939-1-II

consider mitigating factors relating to the youthfulness of a juvenile tried as an adult and/or does not

appreciate its discretion to impose any exceptional sentence in light of that consideration.” In re

Pers. Restraint of Domingo-Cornelio, 196 Wn.2d 255, 268, 474 P.3d 524 (2020). “Unless the court

meaningfully considers youth and knows it has absolute discretion to impose a lower sentence, we

cannot be certain that an adult standard range was imposed appropriately on a juvenile.” Id. Where

a petitioner establishes actual and substantial prejudice, we will remand for resentencing. Id. at 268-

69.

B. APPLICATION

Mejia argues that he is entitled to resentencing because the trial court did not consider the

mitigating factors of youth at his sentencing. It is well established that Houston-Sconiers was a

significant change in the law that is retroactively applicable and material to cases such as Mejia’s

where juveniles were sentenced as adults. Domingo-Cornelio, 196 Wn.2d at 262-65. Accordingly,

Mejia’s petition is not time-barred. Therefore, the question here is whether Mejia has established

actual and substantial prejudice arising from a constitutional error that entitles him to resentencing.

We determine that he has. 3

Here, the trial court was not presented with any evidence or arguments relating to the

mitigating factors of Mejia’s youth, and the court did not meaningfully consider Mejia’s youth on

the record at his sentencing. Notably, although defense counsel briefly referenced Mejia’s age, it

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Related

In Re the Personal Restraint of Hagler
650 P.2d 1103 (Washington Supreme Court, 1982)
In Re the Personal Restraint of Cook
792 P.2d 506 (Washington Supreme Court, 1990)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
State v. Houston-Sconiers
391 P.3d 409 (Washington Supreme Court, 2017)
In re Pers. Restraint of Domingo-Cornelio
474 P.3d 524 (Washington Supreme Court, 2020)
State v. Miller
371 P.3d 528 (Washington Supreme Court, 2016)
In re Meippen
440 P.3d 978 (Washington Supreme Court, 2019)

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